The SCPS/CCPS values the privacy of its members and is committed to upholding each individual’s right to privacy. The information we collect, process or use is treated securely. We respect your privacy and work hard to ensure we meet regulatory requirements. The SCPS/CCPS respects your data and has taken appropriate technical and organisational measures to ensure we have mitigated against such risks as loss or unauthorised access, destruction, use, modification or disclosure of data.
What is the GDPR?
The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age. The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Our Commitment To Data Privacy
The SCPS/CCPS are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
The SCPS/CCPS already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018.
Collection And Use Of Information
The information we collect will be relevant to the purposes for which it is to be used and we will do our utmost to ensure that such information is accurate and complete. Whenever you give us personal data, you are consenting to its collection and use in accordance with this policy. If you are submitting information about another person we will take the submission as confirmation that they have appointed you to act for them and that you are properly authorised to consent on their behalf. Our communications with you may be via post, telephone or email. We’ll keep a record of your calls, emails and other communication in relation to your dealing with us, for reasons including regulatory compliance, crime prevention and detection, for quality control, and for when we need to see a record of what’s been said, and where necessary, for reasons justified by our legitimate interest or our legal obligations.
Your personal data is data which by itself or with other data available to us can be used to identify you. This policy sets out how we’ll use your personal data. We’ll use your personal data for the reasons set out below. The personal data we use may include:
- Full name and personal details including contact information (eg. home address, work address, email addresses, telephone/mobile numbers.
- Date of birth
- Financial details (for direct debit payments, card payments, expenses payments)
- Information from fraud prevention agencies, court records.
- Education and employment details, employment status.
We use your personal data to help us provide advice and to keep you informed of services which we believe will be of interest to you. We may periodically contact you about surveys, job vacancies, courses or other information which we think you may find interesting using the postal or email address which you have provided.
Occasionally you will be asked to submit personal information about yourself (eg. name, address, email) in order to receive or use the CCPS/SCPSs services. Such services include events, newsletters, publications, information and advice. By submitting your details you are consenting to the processing of your information by the CCPS/SCPS. We will use personal information provided by you or gathered by the CCPS/SCPS for the following purposes:
- To process and respond to requests, enquiries and complaints received from you.
- To provide services requested by you.
- To communicate with you about services provided to you.
- To update our records.
- For audit purposes.
- To prevent or detect fraud
- To inform you of products and services that may be of interest to you.
- To enable third parties to carry out any of the purposes above on our behalf.
We collect and use your information in the following situations:
- Where our use of your information is necessary for us to perform the contract that we have with you.
- Where our use of your information is for the purpose of our legitimate interests.
- Where we believe it is necessary to use your information to comply with a legal obligation to which we are subject.
- Where we have your consent. Where we rely on consent to use your information, you have the right to withdraw that consent at any time.
- To manage and process our services with you.
- To update our records.
- For good governance and auditing.
- For activities relating to the prevention, detection and investigation of crime.
- To verify your identity.
Sharing Of Your Personal Data
We will ask for confirmation of identity before we disclose any personal information. We don’t sell your personal data to third parties. We do not share your details with any third parties outside of essential processing.We may disclose your information to our approved service providers, such as mailing houses. We never sell your information with other companies. Subject to application data protection law CCPS/SCPS may share your personal information with third parties in the following ways:
- We will release your personal information when we are required to do so by law.
- We will release your personal information to others when you have given your consent to that release.
- Persons and organisations who help us provide our services and products, and who provide services to us.
- Our legal and other professional advisors.
- Fraud prevention agencies.
- Courts, to comply with legal requirements, and for the administration of justice.
- In an emergency or to otherwise protect your vital interests.
- Payment systems (for direct debit or credit/debit card payments).
The Period For Which We Keep Your Information
We will hold your personal information on our systems for as long as is necessary for the purposes set out above. We will retain your data based on our legal and regulatory requirement.
Your personal data may be converted into statistical or aggregated data which can’t be used to identify you, and then used to produce statistical research and reports.
What Does Our Preparation For Data Privacy Include?
Information Audit- carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
Procedures & Policies - implementing data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
- Data Protection– our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Erasure– we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’and ‘storage limitation’principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities
- Data Breaches– our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures– where The SCPS/CCPS stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
- Legal Basis For Processing– we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- Privacy Notice/Policy– we have revised Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent – we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
- Direct Marketing – we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
- Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website of an individual’s right to access any personal information that The SCPS/CCPS processes about them and to request information about:
- What personal data we hold about them.
- The purposes of the processing.
- The categories of personal data concerned.
- The recipients to whom the personal data has/will be disclosed.
- How long we intend to store your personal data for.
- If we did not collect the data directly from them, information about the source.
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this.
- The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use.
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances.
Information Security And Technical And Organisational Measures
The SCPS/CCPS takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: -SSL, access controls, encrypted members login areas, GDPR roles and employees.
The SCPS/CCPS have designated Valerie Campbell as our Data Protection Officer (DPO) and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures. The SCPS/CCPS understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program. If you have any questions about our preparation for the GDPR, please contact us directly by filling out the contact form below.
If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO) directly using the button below: